ATLANTA--HME providers in Southern California and South Florida will be required to become accredited within a 90-day period under a stipulation in the massive anti-fraud demonstration to be implemented in those areas by CMS.
Providers who do not become accredited within that time after receiving notification from the National Supplier Clearinghouse to do so will lose their Medicare billing numbers, according to details of the initiative.
The requirement has stirred up industry stakeholders, who protested that it is an unreasonable standard.
"You can't get accredited in 90 days," said Miriam Lieber of Lieber Consulting in Sherman Oaks, Calif. "You have to have four months of records; you can barely get the surveyors out [in that period of time] ... This is just not feasible."
"I don't think it can be done in 90 days," agreed Mary Ellen Conway, president of Capital Healthcare Group, Bethesda, Md. "There is such a thing as a provisional accreditation for new companies, but not for existing companies. It's shocking to think that the NSC thinks this can be done in 90 days."
Under CMS' two-year initiative, which is designed to prevent deceptive home care companies from operating in the greater Los Angeles and Miami areas, about 7,700 providers will be required to reapply for their Medicare billing numbers within 30 days of receiving a notice from CMS to re-enroll. (See HomeCare Monday, July 9.)
Those that remain in the system will be subject to "intense review," CMS officials said when they announced the project on July 2. That process will include multiple unannounced site visits by NSC investigators, as well as a "fraud level indicator" for each provider that considers such factors as:
--Experience as a DMEPOS supplier with other payers;
--Prior Medicare experience;
--Specific supplier location;
--Fraud potential of products and services listed;
--Site visit results;
--Inventory observed and contracted; and
--Accreditation of the supplier.
Revocation of billing privileges will occur if "the DMEPOS supplier failed to obtain accreditation from an approved DMEPOS accrediting organization within 90 days of notification from the NSC to do so," according to the demonstration rules.
Providers and consultants quizzed NSC officials during a conference call last week, asking how the timeline could be met given the requirements of accreditation. NSC officials responded that they did not know the details, but that the 90-day time stipulation was what was planned. When contacted by HomeCare, the NSC declined comment.
Conway said full accreditation could conceivably be achieved in 120 days. "It would still be a challenge, and it would have to be tightly watched, but it's doable," she said.
Tim Safley, HME clinical advisor for the Accreditation Commission for Health Care in Raleigh, N.C., one of CMS' 10 approved DMEPOS accrediting organizations, said the 90-day limit could work, but only if the company was in the process of becoming accredited already. If companies in the demonstration areas have not applied, he added, "they've got to get started now. Those companies that wait are going to be put by the wayside."
"They needed to be accredited yesterday," Lieber said bluntly.
Both Lieber and Safley noted that questions still remain about the fraud initiative, including whether the NSC will recognize pending accreditation or whether the company must be fully accredited within the 90 days.
Providers might buy a bit of time depending on when CMS sends its re-enrollment notification letters. No set date was given in the demonstration announcement, although an agency official said the letters would be sent within three to four months.
However, the consultants said, the handwriting is not only on the wall, it is in large, blinking, neon letters: Providers must become accredited, and it is unwise to delay the process any longer.
"There is no legislation [pending] to stop accreditation," Safley said. "It's not going away. If people wait, they are going to miss the window."
CMS is expected to announce a deadline soon by which all providers who bill Medicare will need to be accredited; those in the first round of competitive bidding must be accredited by Aug. 31 in order to win a contract.
Conway pointed out that it isn't just Medicare providers who will be affected by mandatory accreditation. "You have to keep in mind all your payers," she said. "It's going to affect everyone, even if they don't do Medicare. As Medicare goes, so go all the other payers."
Indeed, late last month, Medicaid providers in Oklahoma received a letter from the state's Health Care Authority that said effective Jan.1, 2008, all DMEPOS suppliers "must be accredited by a Medicare-deemed accreditation organization for quality standards for DMEPOS suppliers in order to bill the SoonerCare program."
The state agency said it was making the policy revision to "comply with the [CMS] accreditation standards."
While CMS' two-year fraud initiative could expand to additional areas depending on its success in Miami and L.A., the agency is already planning to implement a similar demonstration project focusing on home health agencies in Harris County (Houston), Texas, and four California counties in the greater Los Angeles area: Los Angeles, Orange, Riverside and San Bernardino.
Under that initiative, announced Tuesday, HHAs in those areas must also re-enroll within 60 days after being requested to do so and must adhere to certain standards. They will also be subject to on-site reviews and, if they have changed ownership within the last two years, a survey.
For an HHS fact sheet on CMS' DME fraud demonstration project, click here.
For a fact sheet on the HHA fraud initiative, click here.
